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N.D. Cal.: Summary Judgement under the Abuse of Discretion Standard

02-09-2018, 12:07 PM

In a case from the Northern District of California, the court handles a rather straightforward motion for summary judgement, ultimately granting it for the Defendant. The only unique thing about the case is a clause in the plan that requires the Plaintiff to pay any fees charged for medical records:

Strickland’s core argument as to why IDSC abused its discretion in denying him benefits is that in previous years the plan administrator had used Strickland’s authorization to obtain his medical records directly from health-care providers, but suddenly IDSC changed policy, instead relying on Strickland to supply these records. Strickland cites to signed authorizations dated May 2014 and April 2016 as evidence of this supposedly abandoned practice. But he does not dispute that the three letters he received prior to denial expressly stated that “IDSC requires that you provide [] the information”; “[i]t is your responsibility to promptly pay any fees charged for medical records”; and “[i]f all of the requested information is not received . . . your claim will be denied for failure to provide information under the plan/program provisions”. Indeed, the plan itself stated that “[a] participant will provide the Plan Administrator with such information and evidence, and will sign such documents, as reasonably may be requested from time to time for purpose of administration of the Plan.

The court, however, was not persuaded by this argument:

To the extent that he bases his argument on the administrative procedures throughout his previous short-term and long-term disability plans, these are not at issue and have no bearing on this distinct plan. The language of the plan is clear, and the actions and ultimate decision of IDCS are consistent with its provisions. IDSC did not abuse its discretion by requiring Strickland to obtain and provide his own medical records, or by denying him benefits when he failed to do so.